PRIVACY POLICY

Privacy Policy

Updated October 2016

Forefront Solutions Limited, whose registered office is at 18-20 Smith Street, St Peter Port, Guernsey GY1 2JQ knows that you care how information about you is used and shared and we appreciate your trust in us to do that carefully and sensibly. This notice describes our privacy policy and forms part of our website terms and conditions ('Website Terms').

The Website is brought to you by ID Pro Guard. ID Pro Guard believes it is important to protect your Personal Data (as defined in the Data Protection Act 1998) and we are committed to giving you a service that meets your needs in a way that also protects your privacy. This policy explains how we may collect Personal Data about you. It also explains some of the security measures we take to protect your Personal Data, and tells you certain things we will do and not do. You should read this policy in conjunction with the Website Terms.

When we first obtain Personal Data from you, or when you take a new service or product from us, we will give you the opportunity to tell us if you do or do not want to receive information by email or text from us about other services or products (as applicable) from us and also selected third party companies in the industry sectors listed in Section 2.1.8, and other companies that we are associated with namely, Forefront Solutions Limited. You can normally do this by ticking specific boxes on an application form or contract. You may change your mind at any time by emailing us at the address below.

info@idproguard.co.uk

Some of the Personal Data we hold about you may be 'sensitive personal data' within the meaning of the Data Protection Act 1998, for example, information about your health or ethnic origin.

Data Controller

Any information that you provide on this website is controlled by Forefront Solutions Limited, which is registered as a data controller with The Office of the Data Protection Commissioner in Guernsey under notification number: 57521. If you have any queries about the information we hold about you, please contact us at info@idproguard.co.uk or write to us at 18-20 Smith Street, St Peter Port, Guernsey GY1 2JQ.

We may collect Personal Data about you from a number of sources, including the following:

1.1 From you when you agree to take a service or product from us, in which case this may include your contact details, date of birth, and your bank details.

1.2 From you when you contact us with an enquiry or in response to a communication from us, in which case, this may tell us something about how you use our services.

1.3 From documents that are available to the public, such as the electoral register.

2. Using your personal information.

2.1. Personal Data about our customers is an important part of our business and we shall only use your Personal Data for the following purposes and shall not keep such Personal Data longer than is necessary to fulfil these purposes:

2.1.1. To help us to identify you when you contact us.

2.1.2. To help us to identify accounts, services and/or products which you could have from us or selected partners from time to time. We may do this by automatic means using a scoring system, which uses the Personal Data you have provided and/or any information we hold about you and Personal Data from third party agencies (including credit reference agencies).

2.1.3. To help us to administer and to contact you about improved administration of any accounts, services and products we have provided before, do provide now or will or may provide in the future.

2.1.4. To allow us to carry out marketing analysis and customer profiling (including using transactional information), conduct research, including creating statistical and testing information.

2.1.5. To help to prevent and detect fraud or loss.

2.1.6. To allow us to contact you in any way (including mail, telephone, visit, text or multimedia messages) about products and services offered by us and selected partners unless you have previously asked us not to do so. Your email address will be shared with our email partner, All Inbox, LLC, for the purpose of mailing you relevant third party email promotions.

2.1.7. We may monitor and record communications with you for quality assurance and compliance.

2.1.8. If you agree, we would like to pass on your personal information to selected third party companies in the following industry sectors, so that they may offer you their products and services.

2.2. We will not disclose your Personal Data to any third party except in accordance with this Privacy Policy.

2.3. We may allow other people and organisations to use Personal Data we hold about you in the following circumstances:

2.3.1. If we, or substantially all of our assets, are acquired or are in the process of being acquired by a third party, in which case Personal Data held by us, about our customers, will be one of the transferred assets.

2.3.2. If we have been legitimately asked to provide information for legal or regulatory purposes or as part of legal proceedings or prospective legal proceedings.

2.3.3. We employ companies and individuals to perform functions on our behalf and we may disclose your Personal Data to these parties for the purposes set out in clause 2.1 or, for example, for fulfilling orders, delivering packages, sending postal mail and email, removing repetitive information from customer lists, analysing data, providing marketing assistance, providing search results and links (including paid listings and links), processing credit and debit card payments and providing customer service. Those parties are bound by strict contractual provisions with us and only have access to Personal Data needed to perform their functions, and may not use it for other purposes. Further, they must process the Personal Data in accordance with this Privacy Policy and as permitted by the Data Protection Act 1998. From time to time, these other people and organisations to whom we may pass your Personal Data may be outside the European Economic Area, which comprises the 27 member states of the European Union plus Iceland, Lichtenstein and Norway. We will take all steps reasonably necessary to ensure that your Personal Data is treated securely and in accordance with this Privacy Policy and the Data Protection Act 1998.

2.4. Where you give us Personal Data on behalf of someone else, you confirm that you have provided them with the information set out in this Privacy Policy and that they have not objected to such use of their Personal Data.

2.5. In connection with any transaction which we enter into with you:

2.5.1. We, and other companies in our group, may carry out credit and fraud prevention checks with one or more licensed credit reference and fraud prevention agencies. We and they may keep a record of the search. Information held about you by these agencies may be linked to records relating to other people living at the same address with whom you are financially linked. These records will also be taken into account in credit and fraud prevention checks. Information from your application and payment details of your account will be recorded with one or more of these agencies and may be shared with other organisations to help make credit and insurance decisions about you and members of your household with whom you are financially linked and for debt collection and fraud prevention. This includes those who have moved house and who have missed payments.

2.5.2. If you provide false or inaccurate information to us and we suspect fraud, we will record this and may share it with other people and organisations. We, and other credit and insurance organisations, may also use technology to detect and prevent fraud.

2.5.3. If you need details of those credit agencies and fraud prevention agencies from which we obtain and with which we record information about you, please write to our Data Protection Manager at 18-20 Smith Street, St Peter Port, Guernsey GY1 2JQ.

2.6. For marketing purposes

2.6.1. We would like to send you information about products and services of ours and other companies in our group which may be of interest to you. If you have consented to receive marketing, you may opt-out at a later date.

You have a right to stop us from contacting you for marketing purposes or giving your information to other members of our group.

2.6.2. We would like to share your personal information with carefully selected third party companies so that they may send you information of services and products that may be of interest to you. If you have consented to receive marketing, you may opt-out at a later date.

You have a right to stop us from sharing your personal information for marketing purposes.

3. Protecting Information

We have strict security measures to protect Personal Data.

3.1. We work to protect the security of your information during transmission by using Secure Sockets Layer (SSL) software, which encrypts information you input.

3.2. We reveal only a few digits of your credit card number when confirming an order.

3.3. We maintain physical, electronic and procedural safeguards in connection with the collection, storage and disclosure of personally identifiable customer information.

3.4. It is important for you to protect against unauthorised access to your password and to your computer. Never write your password down or disclose it to anyone else. Forefront Solutions Limited cannot be held liable for any situations that arise due to unauthorised access which is beyond our control. Be sure to sign off when you finish using a shared computer.

4. Internet

4.1. Please remember that communications over the internet, such as emails and webmails (messages sent through a website), are not secure unless they have been encrypted. Your communications may go through a number of countries before they are delivered - this is the nature of the internet. We cannot accept responsibility for any unauthorised access or loss of Personal Data that is beyond our control.

5. Cookies

When we provide services, we want to make them easy, useful and reliable. This sometimes involves placing small amounts of information on your computer. These are called 'cookies'.

These cookies cannot be used to identify you personally and are used to improve services for you, for example through:

- Letting you navigate between pages efficiently

- Enabling a service to recognise your computer so you don't have to give the same information during one task

- Recognising that you have already given a username and password so you don't need to enter it for every web page requested

- Measuring how many people are using services, so they can be made easier to use and that there is enough capacity to ensure they are fast

Users typically have the opportunity to set their browser to accept all or some cookies, to notify them when a cookie is issued, or not to receive cookies at any time. The last of these options, of course, means that personalised services cannot be provided and the user may not be able to take full advantage of all of a website's features. Refer to your browser's Help section for specific guidance on how it allows you to manage cookies and how you may delete cookies you wish to remove from your computer.

Multiple cookies may be found in a single file depending on which browser you use.

The cookies used on this website have been categorised based on the categories found in the ICC UK Cookie guide, as follows:

Category 1: strictly necessary cookies

These cookies are essential in order to enable you to move around the website and use its features, such as accessing secure areas of the website. Without these cookies services you have asked for, like shopping baskets or e-billing, cannot be provided.

By using this website, you agree that we can place these types of cookies on your device. If you have any queries about these, or would like more information, please contact our Data Protection Manager at 18-20 Smith Street, St Peter Port, Guernsey GY12JQ.

6.1. The Website may include third-party advertising and links to other websites. We do not provide any personally identifiable customer Personal Data to these advertisers or third-party websites.

6.2. These third-party websites and advertisers, or internet advertising companies working on their behalf, sometimes use technology to send (or 'serve') the advertisements that appear on the Website directly to your browser. They automatically receive your IP address when this happens. They may also use cookies, JavaScript, web beacons (also known as action tags or single-pixel gifs), and other technologies to measure the effectiveness of their ads and to personalise advertising content. We do not have access to or control over cookies or other features that they may use, and the information practices of these advertisers and third-party websites are not covered by this Privacy Policy. Please contact them directly for more information about their privacy practices. In addition, the Your Online Choices scheme offers useful information about internet advertising companies (also called 'ad networks' or 'network advertisers'), including information about how to opt-out of their information collection.

6.3. We exclude all liability for loss that you may incur when using these third party websites.

7. Safe Harbor Privacy.

The European Parliament and Council of the European Union adopted Directive 95/46/EC on Data Protection to set standards for the security and transfer of personal data. The Data Directive limits the transfer of personal data to countries outside of the EU and the European Economic Area (EEA) for processing to only those countries that can ensure an adequate level of protection for an individuals personal data. The United States Department of Commerce and the EU developed a set of Safe Harbor Principles regarding personal data privacy and security that, when followed, permit and organization to certify that it provides adequate protection for the transfer of EU personal data to the US for processing. Forefront Solutions Limited fully commits to follow the Safe Harbor Principles with respect to all personal data received from any individual or entity in the EU or the EEA.

8. Further information.

8.1. If you would like any more information or you have any comments about our Privacy Policy, please either write to us at Data Protection Manager, 18-20 Smith Street, St Peter Port, Guernsey GY12JQ, or email us at info@idproguard.co.uk.

8.2. We may amend this Privacy Policy from time to time without notice to you, in which case, we will publish the amended version on the Website. You confirm that we shall not be liable to you or any third party for any change to this Privacy Policy from time to time. It is your responsibility to check regularly to determine whether this Privacy Policy has changed.

8.3. You can ask us for a copy of this Privacy Policy and of any amended Privacy Policy by writing to the above address or by emailing us at info@idproguard.co.uk. This Privacy Policy applies to Personal Data we hold about individuals. It does not apply to information we hold about companies and other organisations

8.4. If you would like access to the Personal Data that we hold about you, you can do this by emailing us at info@idproguard.co.uk or writing to us at the address noted above. There may be a nominal charge of £10 to cover administrative costs. We may contact you to verify that you have actually made the request personally.

8.5. We aim to keep the Personal Data we hold about you accurate and up to date. If you tell us that we are holding any inaccurate Personal Data about you, we will delete it or correct it promptly. Please email us at info@idproguard.co.uk or write to us at the address above to update your Personal Data.

9. Our contact information.

If you have any questions about this privacy statement, the practices of this site, or your dealings with our website, you can contact us via email sent to: info@idproguard.co.uk, via mail to Opt-Out, Forefront Solutions Limited, 18-20 Smith Street, St Peter Port, Guernsey GY1 2JQ.

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